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139 STAT. 288 PUBLIC LAW 119–21—JULY 4, 2025 section 3134 of the Internal Revenue Code of 1986 shall be allowed, and no refund with respect to any such credit shall be made, after the date of the enactment of this Act, unless a claim for such credit or refund was filed by the taxpayer on or before January 31, 2024. (e) EXTENSION OF LIMITATION ON ASSESSMENT.—Section 3134(l) is amended to read as follows: ‘‘(l) EXTENSION OF LIMITATION ON ASSESSMENT.— ‘‘(1) IN GENERAL.—Notwithstanding section 6501, the limitation on the time period for the assessment of any amount attributable to a credit claimed under this section shall not expire before the date that is 6 years after the latest of— ‘‘(A) the date on which the original return which includes the calendar quarter with respect to which such credit is determined is filed, ‘‘(B) the date on which such return is treated as filed under section 6501(b)(2), or ‘‘(C) the date on which the claim for credit or refund with respect to such credit is made. ‘‘(2) DEDUCTION FOR WAGES TAKEN INTO ACCOUNT IN DETER- MINING IMPROPERLY CLAIMED CREDIT.— ‘‘(A) IN GENERAL.—Notwithstanding section 6511, in the case of an assessment attributable to a credit claimed under this section, the limitation on the time period for credit or refund of any amount attributable to a deduction for improperly claimed ERTC wages shall not expire before the time period for such assessment expires under para- graph (1). ‘‘(B) IMPROPERLY CLAIMED ERTC WAGES.—For purposes of this paragraph, the term ‘improperly claimed ERTC wages’ means, with respect to an assessment attributable to a credit claimed under this section, the wages with respect to which a deduction would not have been allowed if the portion of the credit to which such assessment relates had been properly claimed.’’. (f) AMENDMENT TO PENALTY FOR ERRONEOUS CLAIM FOR REFUND OR CREDIT.—Section 6676(a) is amended by striking ‘‘income tax’’ and inserting ‘‘income or employment tax’’. (g) EFFECTIVE DATES.— (1) IN GENERAL.—The provisions of this section shall apply to aid, assistance, and advice provided after the date of the enactment of this Act. (2) LIMITATION ON CREDITS AND REFUNDS.—Subsection (d) shall apply to credits and refunds allowed or made after the date of the enactment of this Act. (3) EXTENSION OF LIMITATION ON ASSESSMENT.—The amendment made by subsection (e) shall apply to assessments made after the date of the enactment of this Act. (4) AMENDMENT TO PENALTY FOR ERRONEOUS CLAIM FOR REFUND OR CREDIT.—The amendment made by subsection (f) shall apply to claims for credit or refund after the date of the enactment of this Act. (h) REGULATIONS.—The Secretary (as defined in subsection (a)(5)) shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section (and the amendments made by this section). Guidance. Applicability. Definition. Time period.